Equivalency of Special Tooling and Equipment

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Ed Gagnon
Ed Gagnon's picture
Equivalency of Special Tooling and Equipment

I am looking for guidance on establishing Equivalency of Special Tooling, Equipment and Test Apparatus. The last guidance I am familiar with is HBAW 00-20A and I cannot locate it. Also AIR-100 issued a memoradum dated 12/21/99 on the subject and I cannot locate that either.

Does current guidance exist on the subject?

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AskBob's picture

I think what you need is in 8900.1, VOLUME 6, CHAPTER 11, Section 20 - Evaluate Special Equipment or Test Apparatus which can be found here: http://fsims.faa.gov/wdocs/8900.1/v06%20surveillance/chapter%2011/06_011...
Tool Equivalency for 145 Repair Stations is also discussed in http://fsims.faa.gov/wdocs/8900.1/v06%20surveillance/chapter%2009/06_009... and http://fsims.faa.gov/wdocs/8900.1/v02%20air%20op%20&%20agency%20cert/cha...
Hope this helps.
Any one else have experience with this subject?

AskBob's picture

Recieved from my FAA contact:
The answer you are looking for can be found in FAR 43.13(a) “He shall use the tools, equipment, and test apparatus necessary to assure completion of the work in accordance with accepted industry practices. If special equipment or test apparatus is recommended by the manufacturer involved, he must use that equipment or apparatus or its equivalent acceptable to the Administrator.

The below information was taken from HBAW 00-20A and added to the AC 145-9 but it explains it pretty good.

If the repair station will be using equipment, tools, or materials other than those recommended by the manufacturer, the manual must explain the procedure it will use for determining equivalency of equipment, tools,and materials. To determine equivalency, compare the technical requirements of the special equipment or test apparatus recommended by
the manufacturer with the proposed replacements. The equipment or test apparatus may look different, be made of different materials, be a different color, and so forth. However, the equipment or test apparatus must be capable of performing all necessary tests and checking all required parameters of the articles. The level of accuracy should be
equal to or better than that the data, drawings, testing, or reports necessary to determine that the article is equivalent to the article recommended by the manufacturer. The basis of equivalency is the requirement that the article meet the manufacturer’s standards and specifications in all respects regarding tolerances, repeatability, and accuracy. Repair stations should review the specific requirements of part 43 before developing equivalent tools and equipment.

Standard industry practice establishes that each piece of special equipment or test apparatus have a unique part number and serial number to identify it within the repair station’s inventory system. Whether the equipment or apparatus is obtained from the manufacturer or produced by the repair station, it should be identified in the system for calibration and tracking purposes.

Hope this helps I have also contact Washington for guidance to be placed in the 8900.1 that better explains it. There are references in the part 145 certification guidance material, but its pretty weak.


Stacheair1's picture

I have worked with several companied to review a data file to show the special tool or equipment meets the OEM by the use of a data file. If a person makes his or her own tool, which is allowed the Administrator must approve it. You are right this can be found in http://fsims.faa.gov/wdocs/8900.1/v06%20surveillance/chapter%2011/06_011...

A certificate holder (A&P or repair station) must make a determination of acceptability for equivalency of special equipment and/or test apparatus used in maintaining aircraft and their associated components.

The term equivalency, as used throughout the above section in the order and means equivalent to that recommended by the Original Equipment Manufacturer (OEM) for the purpose of performing specific tests or making required measurements to determine airworthiness. To determine equivalency, a certificate holder should compare the required test operations or specifications and the technical data of the special equipment or test apparatus (both the data recommended by the manufacturer and the data proposed by the certificate holder). The special equipment or test apparatus may look different, be made of different materials, be a different color, etc. However, as long as the tool is functionally equivalent for the specific test application, the tool may be used.

The accuracy of special equipment or test apparatus used to perform a specific task should be at least equal to that recommended by the manufacturer.

The use of equivalent equipment was first addressed in the Civil Aeronautics Manual 52 (CAM 52), Repair Station Certificates, which preceded Title 14 of the Code of Federal Regulations (14 CFR) part 145. Specifically, CAM 52, section 52.30-1 stated, “The applicant will have the responsibility of choosing suitable tools and equipment (which may be either equipment or tools recommended by a manufacturer in the overhaul or repair of his product or the equivalent of such equipment or tools). The inspecting CAA [Civil Aviation Authority] agent will determine if these tools, equipment, and materials are satisfactory within the intent of this regulation.” This implied that the CAA inspector was to make a determination of equivalency. However, this statement simply established that the CAA inspector determined if the equipment was satisfactory. The intent remains the same today.

A finding of equivalency can only be made based on an evaluation of a technical data file. Additionally, demonstrating functionality of the special equipment or test apparatus may sometimes be required. A technical data file may include, but is not limited to, data, drawings, specifications, instructions, photographs, templates, certificates, and reports. For calibration equipment, the technical data file should also include data sheets attesting to its accuracy when calibration standards are necessary. This file should also describe any special manufacturing processes that are used in the controlling processes, including gauges and recording equipment. If calibration equipment is involved, documented procedures will be used to evaluate the adequacy of the calibration equipment, and the equipment must be traceable to the National Institute of Standards and Technology (NIST) or to a standard provided by the equipment manufacturer. With foreign equipment, a standard of the country of manufacture may be used if found acceptable by the Federal Aviation Administration (FAA).

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